Background

The Menominee River forms the boundary between the northeast
corner of Wisconsin and the southern tip of the Upper Peninsula of
Michigan. The river's headwaters originate in both states. The main
stem of the river flows between the cities of Menominee, Michigan,
and Marinette, Wisconsin before emptying into Green Bay.

The Menominee River Area of Concern (AOC)
includes the lower three miles (4.8 km) of the river from the Upper
Scott Paper Company (Wisconsin) Dam to the river's mouth and
approximately 3.1 miles (5 km) north and south of the mouth along
the adjacent shoreline of Green Bay. The AOC also includes the
cities of Marinette and Menominee, as well as the adjacent nearshore
area of Green Bay, Wisconsin, extending three miles north to John
Henes Park and south of the river mouth to the point of land known
as Seagull Bar. The AOC also includes Green Island.

Land use in the AOC is primarily industrial and residential. A
chemical company, two paper mills, two municipal wastewater
treatment plants, a ship building company, and a foundry are located
along the river. The AOC watershed is shared between Michigan and
Wisconsin. The U.S. Environmental Protection Agency is the lead
agency working on the Ansul Fire Protection Company site. The
Wisconsin DNR is providing support.

Beneficial Use Impairments

Restrictions on fish and wildlife consumption

Degradation of fish and wildlife populations

Beach closings

Degradation of benthos

Restriction on dredging activities

Loss of fish and wildlife habitat

Six of 14 beneficial use impairments have been
identified through the Remedial Action Plan (RAP) process. A primary cause of the identified use impairments is
arsenic contamination in the turning basin and in sediments along
the right bank (downstream direction) of the river below the Ansul
Fire Protection Company, an herbicide production facility, in
Marinette, Wisconsin. This problem was caused from improper arsenic
storage and disposal practices by Ansul from 1957 to 1977. Under
recent RCRA corrective action enforcement efforts, sediment and
groundwater remediation efforts were implemented in the Eighth
Street Slip area.

Other pollutants of concern identified in the AOC included paint
sludge and coal tar. Remediation of the paint sludge site was
completed in 1995, on the Michigan side. The site was remediated
under Act 307 authority. The WPSC Marinette MPG (Manufactured Gas
Plant) "Coal Tar Site" is another significant source of
contamination. It is currently under remedial investigation by the
U.S. EPA Superfund Division. Other pollutants -- such as mercury,
polychlorinated biphenyls (PCBs), and oil and grease – have also
contributed to use impairments. A fish advisory exists for mercury
and PCBs.

Delisting Targets

The following delisting targets are discussed in the most recent
Menominee River AOC RAP document, the 1996 Lower Menominee
River Remedial Action Plan Update(PDF 7.83MB, 177pages). The
purpose of the plan was to guide restoration, where possible, of the
identified impaired uses in the 1990 Stage 1 RAP.

The long-term goals were identified as:

Protect the aquatic ecosystem of the Menominee River and
harbor from the effects of toxic and conventional pollutants.

Maintain a balanced aquatic and terrestrial community to
ensure long term health of the ecosystem

Maintain and enhance recreational and commercial uses of the
Menominee River and Harbor, consistent with the long term
maintenance of the natural resource base and a healthy economy.

Objectives for meeting the long-term goals were identified as:

Evaluate the exposure risks to fish, aquatic life, wildlife,
and human health from in-place pollutants (contaminated
sediments) to determine the need for remediation.

Eliminate all toxic effects to fish and aquatic life from
industrial and municipal discharges.

Identify and eliminate all toxic effects to fish and aquatic
life from polluted runoff.

Maintain water quality in the river and bay as drinkable
after standard treatment.

Maintain a balanced and productive fishery that produces
fish that everyone can safely eat.

Improve water and sediment databases to assist in evaluating
environmental quality in the AOC.

Restore, protect, and enhance environmental corridors in the
AOC.

Limit excess nutrients entering the Menominee River and
harbor area.

Promote public attitudes and perceptions of the waterfront
as a valuable and aesthetic resource.

Develop, improve, and maintain shoreline access and
recreational facilities for public use and enjoyment.

Protect wildlife and fish habitat in nearshore and wetland
areas.

Reduce conflicts among different types of users.

Encourage commercial and industrial developments that build
upon and enhance the value of the waterfront.

Eliminate all raw sewage discharges and overflows and other
known bacterial problems to meet water quality standards for
total and partial body contact (including recreational uses)
throughout the AOC.

Pursue all opportunities to reduce or eliminate all
discharges of toxic substances into the AOC, including direct
discharges to surface waters, runoff from land surfaces, and air
emissions.

RAP Development and Status

The Wisconsin Department of Natural Resources (WDNR)
has worked with the Michigan Department of Environmental Quality (MDEQ)
to develop and implement the RAP for the Menominee River. The
multi-stakeholder Citizens' Advisory Committee (CAC) and a Technical
Advisory Committee (TAC) have been instrumental in the development
of the RAP by mobilizing public support, increasing awareness, and
conducting data and problem analysis. A vision statement for the
desired future state of the Lower Menominee River was developed by
the CAC and used as guidance in the preparation of RAP goals and
objectives that were developed jointly by the CAC and TAC.

Currently, The U.S. Environmental Protection Agency and Wisconsin
Department of Natural Resources are working with Ansul Fire
Protection Company under the RCRA Corrective Action Program to
address arsenic contamination in the AOC.

1995: Paint sludge removal operations were completed
along Green Bay which resulted in the excavation of more than 10
million pounds of hazardous waste from the bay. An additional 20
million pounds of contaminated sediments were removed during
this effort, which was part of an enforcement order issued to
the Lloyd Flanders Furniture Company in Menominee.

RAP Implementation

Recent progress and achievements

A significant amount of progress has occurred since
the RAP process began in 1988. Agreements and programs among
government agencies, municipal authorities, and industry have been
created to address the use impairments. Presented below is a summary
of actions and accomplishments:

Ansul, Inc. is addressing arsenic contaminated sediments and
soil from the river and shore areas in Marinette under a RCRA
order.

CSO (Menominee) and wet weather bypassing (Marinette) have
been corrected under the National Pollutant Discharge
Elimination System permit process.

The paint sludge site remediation was completed in 1995
under Michigan's Act 307 authority.

A navigational dredging project was conducted by the city of
Menominee to allow for oceangoing vessels to access the lower
part of the Menominee River. Completed in summer 1998, the
dredging project partially restored navigation, one of the
impaired beneficial uses listed for the AOC. The dredged
material was disposed of upland.

The City of Menominee is conducting sewer renovations and
had applied for a loan to fund construction of the final
combined sewer overflow elimination project. Construction work
is now completed.

Remediation work on the contaminated paint sludge site
located on Lake Michigan just north of the river has been
completed. MDNR issued a unilateral order under Act 307 to
Flanders Industries (1992) for remedial work at the site that
included cleanup of the shoreline, construction of a dike
(1993), and excavation of 15 tons of paint sludge from Lake
Michigan (1995). Analysis of sampling conducted in 1997 was to
be used to determine if ecological problems still existed at the
site. If the area was free of problems, the dike was to be
dismantled and the site restored in 1997/1998.

The Menominee River was sampled in 1993-1995 as part of the
tributary monitoring portion of the Lake Michigan Mass
Balance Modeling project. Results are available for the
organic pollutants and metals that were part of the mass balance
sampling effort.

A follow-up survey of sediment toxicity was conducted in the
Eight Street slip by WDNR in 1993 and revealed similar results
to the 1989 testing (complete mortality of the aquatic test
organisms Daphnia magna and significant reductions in growth and
weight of the Chironomus tentans). Extremely high concentrations
of arsenic were detected in samples of both assessments.
Sediment and groundwater remediation efforts were initiated in
the late 1990s.

The City of Marinette purchased land in 1992 along the
riverfront near the mouth and along Green Bay as a first step in
a cooperative effort with WDNR to install a 1,000 meter
recreational walkway along the waterfront from the Menekaunee
Bridge to Red Arrow Park. In 1993, the city received a grant
from WDNR and a Coastal Management grant to proceed with the
development of the scenic walkway. The walkway was completed and
provides an environmentally friendly recreational facility for
public enjoyment.

The bulkhead line designation along the river on the
Wisconsin side from Sixth Street to the Menekaunee Bridge was
removed, allowing this section of the river to remain natural
and preventing any more land along the river's edge from being
bulkheaded.

The City of Menominee is in compliance with its National
Pollutant Discharge Elimination System permit combined sewer
overflow (CSO) separation schedule, and with the 1990 Consent
Agreement with the U.S. EPA for corrective action on its CSO/wet
weather discharges at outfall #8 was eliminated in 1992. After
securing a significant portion of construction funding for the
largest CSO (Outfall #2) from the State of Michigan Revolving
Loan Fund, construction was initiated. The separation project
was completed in 1993 and as been closely monitored to determine
the effectiveness of the separation.

The purge well system installed at the Menominee City
Landfill in 1991 has been connected to the sewer system. The
contaminated groundwater is being treated at the Menominee
Wastewater Treatment Plant. A silty sand cap was installed and
seeded with grass at the landfill in 1992. Preliminary reports
indicate that contaminants have been contained on site.

Marinette's wastewater collection and treatment system was
expanded to handle a wet weather flow of 68 million liters (18
million gallons) of wastewater effluent per day.

The City of Marinette developed and implemented an
industrial pretreatment program to reduce disruptions of
wastewater treatment plant operations caused by industrial
discharges.

High concentration of PAHs, typically found in coal tar
waste, had been detected in river sediments adjacent to the
Marinette wastewater treatment plant as well as in on-site soils
and groundwater. The site, a gas manufacturing plant until 1962,
is under investigation with a potentially responsible party to
determine the extent of contamination and to assess remediation
alternatives.

The U.S. Army Corps of Engineers completed a maintenance
dredging operation at the mouth of the Menominee River during
the summer of 1991. The project removed 17,500 m3 of material
from the main channel below the turning basin and restored
channel depths to 6.4-7.0 m. Laboratory analyses indicated that
some of these sediments contained elevated levels of arsenic.

Current projects and outlook

Ansul Arsenic Ground Water Contamination Remediation Project

A project to develop a barrier to cut off arsenic
contaminated ground water contributions to the Menominee
River is in the modeling and design phase. Hope to begin
construction by the end of 2006.

RAP-Related Publications

Community Involvement

A primary goal of the Lower Menominee River RAP is
and has been to include and encourage public participation in RAP
development and implementation. Public participation has focused on:

Community Recognition

Public Meetings

RAP Advisory Committees

Education and Outreach

Community Cleanup Days

School Presentations

Stakeholder Survey

As part of the RAP process, WDNR and MDEQ formed a RAP Citizen's
Advisory Committee (CAC). The CAC included area residents, local
government officials, educators, recreation specialists,
environmentalists, and business and industry representatives from
the Marinette, Wisconsin and Menominee, Michigan area. Also included
were CAC community education and outreach activities were also begun
and will continue throughout the RAP process.